Free Reply/Response Misc - District Court of Connecticut - Connecticut

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ase 3:03-cr-00230;.AHN Document 118 Filed 12/03/2004 Page 1 of 2
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Q_ UNITED STATES DISTRICT COURT K.; ~ .
$° DISTRICT OF CONNECTICUT E
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UNITED STATES OF AMERICA, : CASE NUMBER 3:03 CR 230 (AHN)
vs. :
ARNOLD BELL : NOVEMBER 23, 2004 ,
MEMORANDUM IN SUPPORT OF PAYMENT N
The undersigned CJA appointed counsel for the defendant, Arnold Bell, hereby l
files this memorandum in support of final payment. On or about April 20, 2004, i
counsel filed a motion for interim payment along with a memorandum in support of
payment to justify the legal bill which exceeded the statutoryallowable amount of ’
$5,200.00. The interim bill reflected the work that was performed on the file from
September 4, 2003 through February 26, 2004. Payment was received on or about
September 7, 2004. The final bill that was submitted on November 18, 2004 is
reflective of the legal work that was performed on the file from February 27, 2004
through June 24, 2004.
Following trial, post-trial motions and memoranda were filed, including a motion
for judgment of acquittal and a motion for new trial. The goverrrment vehemently -
opposed the motion. The latter motion also required an evidentiary hearing to
establish that the new evidence was not discoverable prior to the conclusion of trial.
In addition, the presentence interview required an additional trip to Bridgeport
Correctional Center because the Department of Corrections moved the defendant
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ll s .. se 3:03-cr-OO230~Al-IN Document 118 Filed 12/O3/2004 Page 2 of 2 .
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without notifying the probation officer who had confirmed his presence at BCC prior
l to the interview.
1 Defense counsel has exceeded the statutory maximum payment governing
CJA representation. ln light of the foregoing, counsel is respectfully requesting y
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l payment to cover the costs incurred with his representation.
l Respectfully submitted,
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By:
rlliam H. Paetz
Moriarty & Paetzold, LLC
140 Hebron Avenue, Suite 102
Glastonbury, CT 06033
Tel No: (860)657—1010 _
Federal Bar NO. ct10074
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